Achilleas
Mechanical
- Dec 26, 2002
- 4
I know that this is basically a US site and most people may not really deal with European Norms, but you never know.
A general description and three questions follow.
GENERAL DESCRIPTION:
Trying to make things as specific as I can for you, here is the picture of the situation:
- ALL projects take place in a refinery that has been in operation for more than 25 years now
- ALL design and construction are based on ASME and API codes, as applicable.
- The technical design studies have been carried out from a well known engineering company and after their implementation the refinery (or user or owner) forwarded the relevant drawings for the construction of the "shop" and "field" items to various construction companies which further on have their own subcontractors.
- These projects deal with:
I. New projects for the construction of some new units that will start to be built from the very beginning in January 2003.
II. Projects that had started (design and construction) before May 29th 2002 but will finish after that date.
III. Projects for revamping of old units or parts of them (not only repairs but alterations for upgrading apply also)
IV. Projects for repairs of old units or parts of them (characteristics of the units or of their parts will remain the same).
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QUESTION 1 (all projects): Interconnecting Piping
I consider that a complex unit can be generally composed of:
1.1. Pressure Equipment subject to PED hereafter named as "PED equip"(i.e. vessels, valves, piping etc)
1.2. Pressure Equipment excluded from the Directive, hereafter named as "Non-PED equip" (e.g. simple pressure vessels, pumps, compressors etc.)
1.3. Interconnecting Piping
1.4. Steel Structures
1.5. Atmospheric Storage Tanks (i.e. as per API 650)
In our case, the assembly of the above will be under the responsibility of the user (we will be the Third Part Authority there for that purpose) and can be justified as "installation". Our obligation will be to witness/monitor/control the construction and operation activities, perform necessary inspections and testing of a number of items against the codes/standards and quality procedures of the projects in order to issue the final certificate as required by the Hellenic National Regulations (HNR) which is the Law governing such applications here.
I understand that for all the above projects (I to IV) all the "shop" pressure equipment which the "shop" manufacturers (local and foreign) will deliver on site - even if the design has been given by the user - in addition to the HNR has also to comply with the new Directive, unless it is excluded from Art. 1, par. 3.
However, the basic problem is that we can not undoubtedly conclude to the characterization of the piping - if "assembly" or "installation" - which will interconnect the "shop" equipment (both PED and Non-PED).
Analysing the problem, the interconnecting piping will be an assembly of:
1.3.1 pressure components (i.e. pipes, fittings etc) and
1.3.2 pressure equipment such as:
1.3.2.a. pressure accessories: valves, filters, pressure gauges etc
1.3.2.b. safety accessories: safety valves, pressure relieve devices etc
1.3.3 non-pressure items (i.e. supports) which will be considered as part of the piping system anyway
Most of the job will be performed on site although there will be some prefabricated piping components ( =
arts of the isometric drawings that will be constructed in the contractor's installations or workshop very near to the refinery) but ALL the work will be done under the responsibility of the user (through our monitoring/witness and controls both in the field and workshop as the TPA ).
NOTE: The Quality Manuals, Quality Control Plans and Quality Procedures of the main Contractor(s) for the specific projects have been submitted to the user (owner/refinery) or his reps and will be reviewed and commented, where necessary, for approval. All sub-contractors shall work under the requirements of those documents.
Consequently:
A. Following to the guideline 3/2 can we safely consider that we are in case 2 of the guideline and that all the interconnecting piping is joining of items 1.1, 1.2, 1.4 and 1.5 above (plus 1.3.1 and 1.3.2 and 1.3.3) under the responsibility of the user and hence it is an installation which of course is not subject of the Directive and has to comply only with the Hellenic National Regulations for "Safe Construction and Operation of Refinery Installations"?
For your information, the refinery tends to support this consideration (however no decision has been made yet) and I can see that there is a point there, since the basic aim of the PED 97/23 EC is to remove barriers of trade and allow free circulation of goods in the European Market and not to consist a new standard setting up requirements for building industrial installations. In addition, as it can easily be understood, design appraisal by a Notified Body for PED categories III and IV of piping will dramatically increase the cost of the projects.
OR
B. should we consider that case 1 of the guideline applies and interconnecting piping is a pressure equipment - even if it is done under the responsibility and full monitoring and control of the user - and has to comply additionally with the PED? (As I mentioned earlier, I guess that the "installation" in this case will be only the assembly / joining of items 1.1, up to 1.5 above.)
OR
C. Should we consider joining of the interconnecting piping on site as "installation" and all the prefab piping as pressure equipment subject to PED? In this case there are many difficulties in the way that we should monitor the job (e.g. 1. how could we partially appraise the design, where necessary, of only the prefab parts of the isometrics, 2. there will be a mess with CE marking etc)
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QUESTION 2 (projects III and IV): Repairs, alterations, revamping, upgrading etc of units or parts of them.
I am aware of the fact that the PED does not intend to cover any repairs or alterations of pressure equipment or assemblies. However I have seen somewhere in the guidelines that every time we have to evaluate on a case by case basis taking into account whether the basic parameters/characteristics of the pressure equipment or assembly have been changed or not. In some of these projects there will be on site repairs and modifications that will change parameters which influence either the process or the capacity of the equipment/assembly (e.g. reactor with associated piping).
The owner has addressed a question whether in such cases compliance of the repaired or modified equipment/assembly with PED requirements is necessary and moreover if the whole unit needs to comply with the ESR of the Directive. Please have in mind that the same quality system is applying again: The user/owner gets the design from an engineering company, that will also supervise the project, the Contractor (and his sub-contractors) will follow the international codes/standards listed in their contract and the approved by the user's/owner's quality procedures and the construction and operating activities will be inspected and tested by a Third Part Authority.
I suppose that the whole unit has nothing to do with PED. As far as the associated piping is concerned, I would estimate that if it could be characterized as "installation" (for the purposes outlined in QUESTION 1) it would be also out of the scope of the Directive. But this is something that will be clarified by your answer in the previous question, anyway. For the reactor I have no idea of what it should be done.
Please also note that in a unit several items may be repaired or modified and many new items (e.g. new vessels, interconnecting piping etc) may be added. I suppose that for these items PED applies or not as in a new project for each item individually but the installation as well as the whole unit, are out of the scope of the Directive.
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
QUESTION 3 (all projects): Design appraisal.
In Hellas most (if not all) of the oil & gas applications are getting designed and erected as per the ASME/ANSI and API codes/standards. When appraising a design for the purposes of PED, for example B1 module for category III pressure equipment and/or assembly, a Notified Body should ensure/verify that the ESR of Annex I have been fulfilled.
Does this simply require that the N.B. should:
- identify the Annex I, par. 2 PED design requirements in the relevant clauses of the American codes and
- ensure/verify that these have been followed as stated in these particular codes and
- examine that the results derived from the American formulas are numerically correct ?
OR, additionally, a comparison with the results derived from the respective Harmonised European Standards, if applicable, should take place?
As an example, please consider a piping which has been calculated as per the ASME B 31.3 requirements.
In order to prove adequacy of strength (PED Annex I, par. 2.2) of the pipe under the design conditions given, the N.B. should very generally make sure that:
- the requirements of Annex I, par. 2.2 are identified in the relevant paragraphs of ASME B 31.3 (e.g. par. 302.3.5, 302.3.6 and references)
- all requirements of the a.m. code have been fulfilled (i.e. all ASME B 31.3 code stresses for piping design have been calculated: stresses due to: 0. internal pressure (only for the selection of the pipe wall thickness), 1. sustained loads, 2. displacement strains and 3. occasional loads)
- the right formulas have been used and make independent calculations in order to verify the correctness of the manufacturer's results
Is that enough OR the N.B should additionally:
- compare those requirements with those of the Harmonized European Standards (e.g. EN 13480???), where available and applicable?
- compare the results derived from ASME formulas with those extracted from formulas listed in the respective Harmonized European Standards(e.g. EN 13480???), where available and applicable?
In case that such a comparison should have to take place, what happens in the case of absence of a relevant Harmonized European Standard?
Have any typical design appraisal examples for B1 module been issued by the European Community or the Pressure Committee, covering applications such as piping, vessels and heat exchangers designed according various codes such as ASME, BS, MerkBlatter, TEMA etc?
Does anybody have typical examples of design appraisal for piping as per ASME B31.3 and a vessel as per ASME VIII Div.1 and/or 2? If yes, please let me know.
A general description and three questions follow.
GENERAL DESCRIPTION:
Trying to make things as specific as I can for you, here is the picture of the situation:
- ALL projects take place in a refinery that has been in operation for more than 25 years now
- ALL design and construction are based on ASME and API codes, as applicable.
- The technical design studies have been carried out from a well known engineering company and after their implementation the refinery (or user or owner) forwarded the relevant drawings for the construction of the "shop" and "field" items to various construction companies which further on have their own subcontractors.
- These projects deal with:
I. New projects for the construction of some new units that will start to be built from the very beginning in January 2003.
II. Projects that had started (design and construction) before May 29th 2002 but will finish after that date.
III. Projects for revamping of old units or parts of them (not only repairs but alterations for upgrading apply also)
IV. Projects for repairs of old units or parts of them (characteristics of the units or of their parts will remain the same).
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
QUESTION 1 (all projects): Interconnecting Piping
I consider that a complex unit can be generally composed of:
1.1. Pressure Equipment subject to PED hereafter named as "PED equip"(i.e. vessels, valves, piping etc)
1.2. Pressure Equipment excluded from the Directive, hereafter named as "Non-PED equip" (e.g. simple pressure vessels, pumps, compressors etc.)
1.3. Interconnecting Piping
1.4. Steel Structures
1.5. Atmospheric Storage Tanks (i.e. as per API 650)
In our case, the assembly of the above will be under the responsibility of the user (we will be the Third Part Authority there for that purpose) and can be justified as "installation". Our obligation will be to witness/monitor/control the construction and operation activities, perform necessary inspections and testing of a number of items against the codes/standards and quality procedures of the projects in order to issue the final certificate as required by the Hellenic National Regulations (HNR) which is the Law governing such applications here.
I understand that for all the above projects (I to IV) all the "shop" pressure equipment which the "shop" manufacturers (local and foreign) will deliver on site - even if the design has been given by the user - in addition to the HNR has also to comply with the new Directive, unless it is excluded from Art. 1, par. 3.
However, the basic problem is that we can not undoubtedly conclude to the characterization of the piping - if "assembly" or "installation" - which will interconnect the "shop" equipment (both PED and Non-PED).
Analysing the problem, the interconnecting piping will be an assembly of:
1.3.1 pressure components (i.e. pipes, fittings etc) and
1.3.2 pressure equipment such as:
1.3.2.a. pressure accessories: valves, filters, pressure gauges etc
1.3.2.b. safety accessories: safety valves, pressure relieve devices etc
1.3.3 non-pressure items (i.e. supports) which will be considered as part of the piping system anyway
Most of the job will be performed on site although there will be some prefabricated piping components ( =
arts of the isometric drawings that will be constructed in the contractor's installations or workshop very near to the refinery) but ALL the work will be done under the responsibility of the user (through our monitoring/witness and controls both in the field and workshop as the TPA ). NOTE: The Quality Manuals, Quality Control Plans and Quality Procedures of the main Contractor(s) for the specific projects have been submitted to the user (owner/refinery) or his reps and will be reviewed and commented, where necessary, for approval. All sub-contractors shall work under the requirements of those documents.
Consequently:
A. Following to the guideline 3/2 can we safely consider that we are in case 2 of the guideline and that all the interconnecting piping is joining of items 1.1, 1.2, 1.4 and 1.5 above (plus 1.3.1 and 1.3.2 and 1.3.3) under the responsibility of the user and hence it is an installation which of course is not subject of the Directive and has to comply only with the Hellenic National Regulations for "Safe Construction and Operation of Refinery Installations"?
For your information, the refinery tends to support this consideration (however no decision has been made yet) and I can see that there is a point there, since the basic aim of the PED 97/23 EC is to remove barriers of trade and allow free circulation of goods in the European Market and not to consist a new standard setting up requirements for building industrial installations. In addition, as it can easily be understood, design appraisal by a Notified Body for PED categories III and IV of piping will dramatically increase the cost of the projects.
OR
B. should we consider that case 1 of the guideline applies and interconnecting piping is a pressure equipment - even if it is done under the responsibility and full monitoring and control of the user - and has to comply additionally with the PED? (As I mentioned earlier, I guess that the "installation" in this case will be only the assembly / joining of items 1.1, up to 1.5 above.)
OR
C. Should we consider joining of the interconnecting piping on site as "installation" and all the prefab piping as pressure equipment subject to PED? In this case there are many difficulties in the way that we should monitor the job (e.g. 1. how could we partially appraise the design, where necessary, of only the prefab parts of the isometrics, 2. there will be a mess with CE marking etc)
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
QUESTION 2 (projects III and IV): Repairs, alterations, revamping, upgrading etc of units or parts of them.
I am aware of the fact that the PED does not intend to cover any repairs or alterations of pressure equipment or assemblies. However I have seen somewhere in the guidelines that every time we have to evaluate on a case by case basis taking into account whether the basic parameters/characteristics of the pressure equipment or assembly have been changed or not. In some of these projects there will be on site repairs and modifications that will change parameters which influence either the process or the capacity of the equipment/assembly (e.g. reactor with associated piping).
The owner has addressed a question whether in such cases compliance of the repaired or modified equipment/assembly with PED requirements is necessary and moreover if the whole unit needs to comply with the ESR of the Directive. Please have in mind that the same quality system is applying again: The user/owner gets the design from an engineering company, that will also supervise the project, the Contractor (and his sub-contractors) will follow the international codes/standards listed in their contract and the approved by the user's/owner's quality procedures and the construction and operating activities will be inspected and tested by a Third Part Authority.
I suppose that the whole unit has nothing to do with PED. As far as the associated piping is concerned, I would estimate that if it could be characterized as "installation" (for the purposes outlined in QUESTION 1) it would be also out of the scope of the Directive. But this is something that will be clarified by your answer in the previous question, anyway. For the reactor I have no idea of what it should be done.
Please also note that in a unit several items may be repaired or modified and many new items (e.g. new vessels, interconnecting piping etc) may be added. I suppose that for these items PED applies or not as in a new project for each item individually but the installation as well as the whole unit, are out of the scope of the Directive.
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
QUESTION 3 (all projects): Design appraisal.
In Hellas most (if not all) of the oil & gas applications are getting designed and erected as per the ASME/ANSI and API codes/standards. When appraising a design for the purposes of PED, for example B1 module for category III pressure equipment and/or assembly, a Notified Body should ensure/verify that the ESR of Annex I have been fulfilled.
Does this simply require that the N.B. should:
- identify the Annex I, par. 2 PED design requirements in the relevant clauses of the American codes and
- ensure/verify that these have been followed as stated in these particular codes and
- examine that the results derived from the American formulas are numerically correct ?
OR, additionally, a comparison with the results derived from the respective Harmonised European Standards, if applicable, should take place?
As an example, please consider a piping which has been calculated as per the ASME B 31.3 requirements.
In order to prove adequacy of strength (PED Annex I, par. 2.2) of the pipe under the design conditions given, the N.B. should very generally make sure that:
- the requirements of Annex I, par. 2.2 are identified in the relevant paragraphs of ASME B 31.3 (e.g. par. 302.3.5, 302.3.6 and references)
- all requirements of the a.m. code have been fulfilled (i.e. all ASME B 31.3 code stresses for piping design have been calculated: stresses due to: 0. internal pressure (only for the selection of the pipe wall thickness), 1. sustained loads, 2. displacement strains and 3. occasional loads)
- the right formulas have been used and make independent calculations in order to verify the correctness of the manufacturer's results
Is that enough OR the N.B should additionally:
- compare those requirements with those of the Harmonized European Standards (e.g. EN 13480???), where available and applicable?
- compare the results derived from ASME formulas with those extracted from formulas listed in the respective Harmonized European Standards(e.g. EN 13480???), where available and applicable?
In case that such a comparison should have to take place, what happens in the case of absence of a relevant Harmonized European Standard?
Have any typical design appraisal examples for B1 module been issued by the European Community or the Pressure Committee, covering applications such as piping, vessels and heat exchangers designed according various codes such as ASME, BS, MerkBlatter, TEMA etc?
Does anybody have typical examples of design appraisal for piping as per ASME B31.3 and a vessel as per ASME VIII Div.1 and/or 2? If yes, please let me know.